1. Preamble and Acceptance
Where the processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. However, please note that such withdrawal:
– does not call into question the lawfulness of any processing carried out prior to such withdrawal and based on your consent;
– may result in you no longer being able to make use of certain features of the Website.
2. Data Controller
2.1 If you have any questions, please do not hesitate to contact us via email@example.com. We will be happy to answer them.
2.2 You may also contact us by post at Boulevard Georges-Favon 43, 1204 Geneva.
3. General Principles
3.1 The information collected on our Website enables us to provide the following services:
(i) links to other websites.
4. Personal Data that We Collect
4.2 The Personal Data we collect when you visit the Website may include: your first
and last name, email address and IP address.
5. The Purpose of the Collection of the Personal Data
We use the Personal Data that you provide us with for the following purposes:
(i) to enable you to use the interactive features of the Website when you wish to do so
6. Grounds for processing
6.1 Regarding the use of the Website, we justify the processing of your Personal Data notably on the basis of article 13(1) of the Swiss Federal Act on Data Protection (“FADP”).
7. Personal Data Collected by Third Parties (Links to Other Websites)
7.2 Our Website may contain links that take you to other websites, in order to enable you to access the content available on these platforms. When you access another website through our Website, it is the relevant service provider’s responsibility to comply with applicable data protection requirements.
7.3 When you establish a connection to a website, your browser connects directly to the server of the relevant service provider. Through this connection, the website receives the information that your browser has accessed on the relevant page of our Website. This information (including your IP address) is transmitted from your browser directly to the service provider’s server and stored there.
8. Disclosure of Your Personal Data to Third Parties
8.1 We may provide access to the Personal Data that you have provided to us through our Website to certain independent contractors and affiliated companies to assist us in the operation of the Website. To date, these contractors are as follows:
(i) Sales and Marketing platforms
(ii) Email system provider
8.3 The purpose of sharing your Personal Data with the aforementioned third parties is to ensure our business, as well as to maintain and seek to constantly improve our Website, and the services offered to our users. The grounds on which we justify the processing of your Personal Data to this respect is article 13(1) and (2) FADP, which authorizes us to process Personal Data when such processing is necessary for the purposes of our legitimate interests.
9. Communication of your Personal Data to the Authorities
9.2 We may be required to disclose your Personal Data when required to do so by law
or when we have a good faith belief that such disclosure is necessary to:
(i) investigate, prevent or take action in relation to potential or actual illegal activities or to assist administrative enforcement authorities,
(ii) to execute an agreement between us and you,
(iii) to investigate and defend against a complaint or allegation from third parties,
(iv) protect the security and integrity of our Website or
(v) exercise and protect the rights and safety of our users, employees or others.
9.3 We shall attempt to notify you of third-party requests for your Personal Data when we believe it is appropriate and technically feasible to do so, except where we are prohibited from doing so by law or an order of authority or where the request is urgent. We may challenge such requests when, in our sole discretion, we consider that the request is formulated too broadly, is too vague or is unfounded, but we do not
guarantee to challenge any request.
9.4 The purpose of sharing your Personal Data with the aforementioned authorities is to meet our obligation under article 13(1) FADP, which authorizes us to process Personal Data when such processing is necessary to comply with a legal obligation to which we are subject.
10. Cross-Border Disclosure of Personal Data
11. Protection of your Personal Data and Notification of a Data Breach
11.1 We undertake to use all commercially reasonable means to prevent any exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (including administrative, physical and technical measures) to deal with unauthorized disclosure or exposure of your Personal Data.
11.2 In the event of an actual or suspected breach of Personal Data, we will
(i) use our best efforts to notify you promptly, where technically feasible, and
(ii) cooperate with you to investigate and resolve the breach, including, but not limited to, providing you with reasonable assistance in notifying affected third parties. We undertake to provide you with access, without delay and upon reasonable request, to our records relating to the breach of your Personal Data, provided, however, that this does not give you access to records that belong to other users or that could compromise their security.
11.3 In the event of an actual or suspected breach of Personal Data, we undertake to notify the relevant authority under applicable law.
12. Your Rights with Regards to your Personal Data
12.1 Right of rectification: You have the right to obtain the rectification of your Personal Data if it is inaccurate or incomplete.
12.2 Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.
12.3 Right to limit the processing: Within the limits of the law, you have the right to obtain a limitation of the processing of your Personal Data.
12.4 Right to portability of Personal Data: You have the right to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format.
12.5 Right to Withdrawal of Consent: Within the limits of the law, you have the right to withdraw your consent at any time when the processing of your Personal Data relies on it.
12.6 Right to complain to an authority: You have the right to complain to any competent authority about the collection and use of your Personal Data.
12.7 We may ask you to prove your identity before responding to a request based on the above rights or otherwise related to your Personal Data.
13. Retention of your Personal Data
13.1 We retain the Personal Data you provide to us to the extent required to access and use our Website and its features (such as our newsletter registration forms), as well as to the extent required to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce agreements we have entered into and our internal regulations.
13.2 We reserve the right to store the data in an anonymized form after deletion of your Personal Data.
14. Security of your Personal Data
We attach great importance to the security of your Personal Data. However, no method of communication over the Internet or method of electronic storage guarantees 100% security. Therefore, although we strive to use commercially acceptable technical and organizational means to protect your Personal Data, we cannot guarantee its absolute security.
15. Personal Data Relating to Children
We do not provide services specifically targeted at children and we do not proactively collect Personal Data from children.